Anti-money Laundering Policy

Purpose and Scope

This anti-money laundering (AML) policy governs all activities conducted by Rk77 in connection with gaming, payments, and related services. It establishes the minimum standards for identifications, risk assessment, ongoing monitoring, reporting, and cooperation with authorities to prevent money laundering and the financing of wrongdoing.

Regulatory Framework and Governance

Rk77 operates in compliance with applicable anti-money laundering laws and regulations. The policy is designed to reflect a risk‑based approach and to support ongoing regulatory reporting, cooperation with competent authorities, and transparent governance of AML controls. Personal data processed for AML purposes is subject to data protection laws, including GDPR where applicable, and is handled by the data controller responsible for AML processing.

Risk‑Based Approach and Customer Due Diligence

Rk77 applies a risk‑based framework to determine the extent of due diligence required for each customer and transaction. The three tiers of due diligence are defined as:

1. Simplified Due Diligence (SDD) for extremely low‑risk, low‑volume activity that does not meet predefined thresholds.
2. Customer Due Diligence (CDD) for standard customer verification and ongoing monitoring.
3. Enhanced Due Diligence (EDD) for high‑risk customers, complex structures, or transactions that trigger elevated risk indicators.

Triggers for full KYC and enhanced verification include the following thresholds and indicators:

• Aggregate lifetime deposits reaching EUR 5,000 or more; or
• Withdrawal requests that generate elevated risk signals; or
• Any transaction or sequence of transactions deemed suspicious by monitoring systems or staff.

Know Your Customer (KYC) Verification Procedures

When KYC is required, customers must complete identity verification by providing the following documentation and information, which must be current and consistent with the customer’s profile:

• Government‑issued photo ID (front and back) showing full name, date of birth, and photograph; and
• A selfie of the customer holding the same identity document; and
• Proof of residential address (e.g., bank statement or utility bill) issued within the last three months; and
• Evidence that the customer is at least 18 years of age and not subject to internal or regulatory restrictions on participation.

The Company shall determine the authenticity and consistency of submitted documents and may perform internal checks or use approved verification methods. If identity cannot be established to the required standard, Rk77 reserves the right to suspend, restrict, or deny access to services, including payments, until verification is complete.

Ongoing Monitoring and Transaction Controls

Rk77 conducts ongoing monitoring of customer activity and transactional behavior on a risk‑based basis. This includes real‑time or periodic reviews of deposits, bets, payouts, and payment methods for patterns indicative of money laundering or financing of illegal activity. Transactions triggering risk indicators may be paused, blocked, or escalated for investigation while maintaining customer protection and regulatory compliance.

Data Retention, Access and Rights

Personal data collected for AML purposes will be retained for eight (8) years from the date of the last relevant activity, or for a longer period where required by law. The data controller for AML processing is Rk77. Data subjects retain rights to access, rectify, erase, restrict processing, and object to processing in accordance with applicable data protection laws and regulations.

Suspicious Activity Reporting and Cooperation

Rk77 shall promptly identify and report suspicious activities or transactions to the competent authorities in accordance with applicable law. The company cooperates with law enforcement and regulatory investigations and maintains auditable records of AML controls, investigations, and internal decisions regarding potential suspicious activity.

Sanctions, Jurisdictional Risk and Restricted Jurisdictions

Rk77 applies enhanced due diligence or denies access to services for customers originating from high‑risk jurisdictions or presenting elevated risk indicators, in line with sanctions and regulatory requirements. The company may restrict or suspend any service, including payments or withdrawals, where such action is required by law or internal policy to mitigate risk.

Training, Policy Review and Internal Controls

Rk77 provides AML training to relevant staff to ensure effective implementation of this policy. The policy and its controls are reviewed at least annually and updated to reflect changes in regulation, risk assessment findings, and incident learnings. Recordkeeping, audit trails, and management oversight underpin continuous compliance.

Policy Accessibility and Contact

Guidance on AML controls is available to customers through compliant channels. Any questions or requests related to this policy should be directed to the designated compliance function via customer support. The policy takes effect upon publication and supersedes prior AML statements.